Home / Blog / CRA letter on whether a charitable foundation is allowed to make a gift to a US charity

CRA letter on whether a charitable foundation is allowed to make a gift to a US charity

Share

Published January 21, 2013by Mark Blumberg

The CRA recently wrote a letter in French on whether charitable foundations are allowed to make gifts to section 501(c)(3) US charities, because of paragraph 7 of article XXI of the U.S. Tax Convention? The CRA answered no. Their reason is that American charities are not deemed to be qualified donees under paragraph 7 of article XXI of the Canada-U.S. Tax Convention.

Charity Law List

The material on this site is for general information and it is not offered as legal advice or opinion. Canadian Charity Law is a project of Blumberg Segal LLP, a law firm based in Toronto, ON. If you would like to discuss your specific legal concerns please contact us.